The London Assembly’s planning and regeneration committee said Riski Sunak’s government should ‘introduce a mandatory requirement in national policy to undertake WLC assessments for buildings’ to address the ‘huge gap’ that currently exists.
The recommendations were set out in its Retrofit vs Rebuild report published yesterday (7 February) following an inquiry last March into how the government and the mayor were addressing embodied carbon.
The committee reported that it had been ‘clear from our investigation that embodied carbon [was] an urgent issue in the context of the climate emergency’.
At present, WLC assessments are required for major developments in the capital that are referable to the mayor – the requirement has been in force since 2021 when the current London Plan was published. But there is no such policy in the rest of England and the committee suggested any national policy could reflect the London plan.
Speaking at the inquiry last year, former Igloo Regeneration chair Chris Brown (now managing director of Climatise) said: ‘It is undeniable that the GLA is a national leader in planning policy in this area [WLC Assessments]. Sadly though, England is a laggard in the developed world and so we are not a global leader, and it is quite interesting to look at other countries.’
The AJ has previously reported that many regard WLC assessments as ‘an emerging art’ and that their results are often disputed. Some campaigners claim that developers pay consultants to produce reports that suggest retrofit is less viable from a carbon perspective than rebuilding.
Perhaps with this in mind, the committee is also pushing for developers in London to pay for a third-party audit of their WLC assessments.
Report extract
Arguably, embodied carbon is increasingly becoming a factor in planning decisions. However, the inquiry and intense disputes concerning the building’s future also showed the complexity of WLC assessments and the difficulty of weighing these up with the many other factors that are involved in a planning decision.
We believe that this case underlines why WLC assessments are essential for major developments and should be built into national policy; and why we need to encourage assessments that are more transparent, accountable and credible. We have made a series of recommendations on this basis.
Members also want the Greater London Authority (GLA) to require developers to assess the carbon implications of retrofitting a building instead of rebuilding.
Some campaigners have also argued that local authorities are not always equipped to analyse WLC assessments. Twentieth Century Society director Catherine Croft told the AJ in 2022 that ‘those tasked with assessing the ever-increasing amount of information that descends on them are starved of training and money’.
The committee said in its report that the mayor and the government should work together to think of ways to help local councils ‘to promote whole-life carbon and circular economy approaches.
The GLA also urged ministers to consider scrapping or cutting VAT on refurbishments as part of a wider drive to encourage retrofit, having heard from experts that, under the current tax rules, the ‘costs associated with retaining and reusing elements of a building can be higher than demolishing and rebuilding’.
The committee’s other recommendations include a call to publish the capital’s WLC data annually to track the success of the assessments policy.
Committee chair Sakina Sheikh said that planning policy ‘can be the key to unlocking climate action’.
She added that WLC assessments ‘would provide essential support for developers and planning authorities to reduce carbon in how they construct.
‘Retrofitting existing buildings and homes can make people warmer and lessen the impact on their energy bills. The government can make retrofitting more financially viable by heeding the calls from industry to reduce the VAT that builders currently have to pay to retrofit.
‘The committee believes that the cross-party recommendations in this report can help London build the homes we need while meeting our aspiration of reaching net zero by 2030. The government and mayor must work together to achieve this.’
Recommendations in full
Recommendation 1
The government should introduce a mandatory requirement in national policy to undertake WLC assessments for buildings, looking at the policy on minimising greenhouse gas emissions set out in the London Plan’s Sustainable Infrastructure Policy 2 Part F as a potential model.
Recommendation 2
The mayor should publish annual data gathered from WLC assessments to enable the success of the policy to be tracked and to identify improvements needed. The GLA should analyse the data and provide an estimate of the amount of embodied carbon emissions associated with London developments, broken down by type.
Recommendation 3
The GLA should explore the following measures in the next iteration of the WLC assessments guidance, to standardise assumptions and improve the ambition, accuracy and accountability of the assessments submitted by developers:
•ambition – more ambitious ‘standard’ and ‘aspirational’ benchmarks to match global best practice
•accuracy – applicants should be required to incorporate electricity grid decarbonisation projections into their assessments
•accountability – a full assessment of the carbon implications of alternatives that involve retrofit; and a requirement for a third-party, independent audit of the WLC assessments (with the cost borne by applicants).
Recommendation 4
The government should assess how to ensure retrofit is more frequently viable, including whether VAT on building refurbishment could be removed or reduced (to bring retrofit in line with new buildings), subject to budgetary and other considerations.
Recommendation 5
The government and the mayor should assemble a working group to identify the support that local authorities need, in terms of their skills and capacity, to promote whole life
Recommendation 6
As part of a potential review of the London Plan, the GLA should conduct a review of the infrastructure, products and services that are needed to support the circular economy in building and construction. As a result of this review, the GLA should set out actions it will take.